One of my favorite stories of 2025 is the saga of the Telnyx FCC robocall scam.

Although that’s probably a pretty bad name for it because Telnyx claims it had nothing to do with it.

As a reminder, some robocallers apparently got ahold of a list of phone numbers belonging to FCC staffers and telecom lawyers in D.C. and decided to make scam calls to them– I am serious.

Now calling a bunch of sophisticated telecom lawyers and commission staff is probably the LEAST effective way to pull off a scam so it begs the question of what these guys were really up to.

Regardless, what we know happened was the carrier the bad guys used–Telnyx– was targeted for a $4mm penalty under the Commission’s amorphous know-your-customer rules, which have never really been explained.

But the FCC’s “know-it-when-we-see-it-and-we-definitely-see-it-here” approach did considerable damage to Telnyx, who hit back with one of the best responses you’ll ever see to a NAL.

And that’s where things have sat for the better a year.

But last week Telnyx came roaring back into the fray taking issue with language from the FCC’s recent NPRM suggesting it was a bad actor and pointing at Telnyx as an example of why carriers need to provide certain disclosures to the Commission.

Specifically the FCC stated:

“We have also expanded robocall mitigation requirements for all providers, and taken major enforcement action against bad actors[fn 11]”

[Fn]: Robocall Mitigation Database Filers, EB-TCD-25-00038590, Order, DA-25-737, 2025 WL 2496602 (EB Aug. 25, 2025) (removing an additional 1,203 non-compliant voice service providers from the Robocall Mitigation Database); Telnyx, LLC, Notice of Apparent Liability, FCC 25-10, 2025 WL 435678 (2025) (finding insufficient know-your customer practices); Sumco Panama SA et al., File No. EB-TCD-21-00031913, Forfeiture Order, FCC 23-64 (Aug. 3, 2023) (levying an historic fine of almost $300 million against a variety of entities which placed over five billion illegal auto warranty robocalls to consumers between January 2021 and March 2021); One Eye LLC, File No. EB-TCD-20 00031678, Final Determination Order, DA 23-389 (EB May 11, 2023) (prohibiting voice service providers from accepting call traffic from One Eye LLC); Urth Access, LLC, File No. EB-TCD-22-00034232, Order, DA 22-1271 (EB Dec. 8, 2022)[others…]

Telnyx took offense to the suggestion it was a “bad actor” and filed a comment–you can read here https://www.fcc.gov/ecfs/document/120358664186/1– reminding the Commission that a NAL is not a final determination of wrong doing. It “urges” the Commission:

Remove any reference to Telnyx or the Telnyx Notice of Apparent Liability (NAL) in Footnote 11 of the Draft or in any other part of the Draft in a manner that falsely asserts or suggests that there has been a final adjudication concerning Telnyx, including that the Commission made any “finding” against Telnyx or that Telnyx is a “bad actor.”

Yikes.

It also tells the FCC to scrap its contemplated disclosure of any investigations rule and instead require disclosure of only final determinations of wrong doing:

If the Commission insists on considering enforcement history, it should: (1) limit any certification to final Commission or court orders finding willful or repeated violations of robocall/spoofing obligations, which is consistent with Section 504(c); (2) allow providers to explain the age, circumstances, and remediation of those matters; and (3) make explicit that being “subject to an investigation” by itself, will not result in the denial or conditioning of a numbering authorization.

Fascinating stuff.

Telnyx has really risen to be a thorn in the FCC’s side and a very aggressive advocate for the rights of telco providers and callers alike. Very cool to see.